After consulting with industry stakeholders, the Monetary Authority of Singapore (MAS) published its response to feedback and amendments to the anti-money laundering and countering the financing of terrorism (AML/CFT) notices and guidelines for financial institutions (FIs) and variable capital companies (VCCs).  The amended notices and guidelines take effect on 1 July 2025.

We highlight some key points from the updated AML/CFT notices and guidelines.

Conduct of Proliferation Financing Risk Assessments

The amended AML/CFT notices provide that money laundering (ML) risks include proliferation financing (PF) risks.  In this regard, MAS clarified that PF assessments may be conducted separately or alongside ML and terrorism financing (TF) assessments, and should be done completed promptly.

Due Diligence on Trusts and Trust Relevant Parties

Under the amended AML/CFT notices, due diligence must be conducted on “trust relevant parties” – namely, the settlor, trustee, protector, beneficiary, and persons with certain powers under the legal arrangement instrument.  MAS clarified that source of wealth due diligence should be conducted on all higher risk trust relevant parties who contribute assets to the legal arrangement.

The amended AML/CFT notices now also require:

• Identification of the “place from where the legal person or legal arrangement is administered”.  For legal persons, this refers to the registered address or main place of operations.  For legal arrangements, it is the location where trust activities – such as maintaining accounting records and exercising trustee powers – are carried out.

• Obtaining a copy of the trust deed, or its equivalent, for identification.  If the deed is unavailable due to confidentiality, MAS allows FIs and VCCs to use reasonable alternatives, such as reliable extracts or a deed of appointment.

Due Diligence on Beneficial Owners

In line with MAS circulars and FATF guidance, FIs and VCCs must identify the beneficial owners (BOs) – who must be natural persons – and obtain their residential addresses. However, due to practical challenges, MAS allows the use of a BO’s business address in certain cases. Where control is exercised through a chain of legal persons or arrangements, required information must be obtained for each entity in the chain.

Suspicious Transaction Report Filing Timelines

Previously, Suspicious Transaction Reports (STR) had to be filed within 15 business days of the case being referred by the relevant employee or officer, unless the circumstances are exceptional or extraordinary.  Under the amended AML/CFT guidelines, that period is now 5 business days from when suspicion is first established – that is, when an FI or VCC concludes that an STR filing is warranted based on its investigations.  While MAS has not set a fixed timeline for investigations, it expects them to be completed promptly.

Conclusion

FIs and VCCs should review their processes and procedures to ensure that they comply with the updated AML/CFT notices and guidelines.  For instance, STR filing and client due diligence processes may need to be updated to align with the new requirements.

For More Information

OrionW regularly advises clients on financial services regulatory matters.  For more information about this, or if you have questions about this article, please contact us at fintech@orionw.com.  

Disclaimer: This article is for general information only and does not constitute legal advice.